Japan-headquartered TOYO plans to build a 1.5GW HJT solar cell manufacturing facility in the Houston metropolitan area of Texas, with an estimated investment of around USD 357 million. Engineering, design and procurement work are already underway, with pilot production and project completion targeted within the next 20 months. The facility will be co-located with TOYO’s existing Houston module plant, which currently has 1GW of annual capacity and is planned to expand to 2GW in 2026. TOYO said HJT provides a platform for future perovskite integration, while domestic cell production will improve efficiency, lower logistics costs and support a FEOC-compliant US supply chain. SMM believes US trade scrutiny and manufacturing incentives are accelerating localized cell capacity deployment among PV manufacturers.

From June 3 to June 5, the Indonesia Critical Minerals 2026 was held at the Pullman Jakarta Central Park in Jakarta, Indonesia. The conference was organized by Shanghai Metals Market (SMM) and co-organized by the Indonesia Nickel Miners Association (APNI) , the Ministry of Foreign Affairs of the Republic of Indonesia , the National Economic Council of Indonesia , and MMR , with a strategic partnership established with the Jakarta Futures Exchange . The conference featured six dedicated forums: the main forum, the nickel and cobalt forum, the tin forum, the coal & energy transition forum, the aluminum forum, and the sub-forum, bringing together 3,500+ attendees from 45 countries and regions worldwide, with 120+ speakers sharing their insights on market prices, supply-demand patterns, industry policies, low-carbon development, and ESG construction, etc. Conference Background In the process of global industrial upgrading, the strategic value of critical metals has become increasingly prominent, and Southeast Asia has gradually emerged as a highly dynamic segment of the global mining landscape. As a major regional mineral producer, Indonesia has successively introduced multiple industrial policies for critical metals such as nickel, tin, aluminum, and copper, adjusting and optimizing areas including mining quotas, pricing mechanisms, tax policies, export management, and domestic market obligation since 2026. These efforts are guided by the goals of improving the regulatory system, enhancing industrial added value, and optimizing resource revenues, and have had a significant impact on the global metal supply chain and market dynamics. As Indonesia’s premier flagship event for the mineral industry, this conference focuses on supply chain security of critical minerals including nickel, cobalt and tin, and adopts a dual-driven model of mining and energy. It commits to promoting Indonesia’s industrial upgrading from raw material export to high-value industrial chain development, while providing solid resource support and practical cooperation paradigms for regional and global energy transition. 》Click to view the photo gallery of the conference June 3: Main Forum Opening Ceremony Adam Fan, Chairman, Shanghai Metals Market Nanan Soekarna, Chairman, APNI Arif Havas Oegroseno, Vice Minister, Ministry of Foreign Affairs Ciyong Zou, Deputy to the Director General and Managing Director of the Directorate of Technical Cooperation and Sustainable Industrial Development, UNIDO (United Nations Industrial Development Organization) Sherly Tjoanda, Governor of North Maluku, North Maluku Government Todotua Pasaribu, Vice Minister, Ministry of Investement and Downstream Industry of Indonesia Drum Performance & Dance Show Opening Address Speaker: Adam Fan, Chairman of SMM Adam stated that this year marks the 4th year of the Indonesia Critical Minerals Conference. This flagship industry event is dedicated to building a global platform connecting Indonesia with the world. Empowering mineral resources through technology, the conference links producers and consumers to facilitate industrial chain and business cooperation. Boasting a record-high attendance, this year’s event gathers 3,500+ participants and 120+ speakers. The growing participation of global countries, enterprises and industry professionals demonstrates rising international trust and confidence in Indonesia’s critical mineral ecosystem. As cross-border collaboration is essential for building a robust global critical minerals supply chain, the conference strives to enhance supply chain transparency, interconnectivity and in-depth global industrial cooperation by pooling industry insights and resources. Speaker: Nanan Soekarna, Chairman of APNI Nanan Soekarna stated in his remarks that the 4th Indonesia Critical Minerals was the largest to date in terms of attendance, demonstrating the global industry’s full confidence in Indonesia’s minerals industry, cross-border cooperation models, and Indonesia’s roadmap for sustainable mining development, and he extended his sincere gratitude to all participating partners. He noted that the core of development in the critical minerals sector has shifted from a simple contest of resources and capacity to the transformation of the sustainable value of natural resources, balancing diverse economic, social, and environmental benefits. By deepening downstream industry chain expansion, Indonesia aims both to enhance industrial value-added and to build an international industrial brand and strengthen credibility in the global market. In the future, the core of global mining competition will not lie in resource reserves, but in transparent, responsible, and sustainable resource governance capabilities. Relying on global partners, Indonesia will uphold the philosophy of sustainable mining development and, through high-quality cooperation and shared value principles, work together to build the future of the critical minerals industry that balances ecology, benefits, and long-term development. Speaker: Arif Havas Oegroseno, Vice Minister, Ministry of Foreign Affairs Arif Havas Oegroseno mentioned that critical minerals are increasingly becoming a focal point of global geopolitical competition, with elements such as energy, minerals, and trade and economic rules being instrumentalized from time to time. Leveraging its domestic resource endowments, Indonesia is vigorously advancing downstream deep processing of minerals; this strategy is not limited to industrial upgrading, but is also a comprehensive development initiative that boosts employment, consolidates science and technology innovation capabilities, enhances industry chain resilience, and delivers inclusive gains from green development. In response to procurement demands from multiple parties, Indonesia adheres to a diversified cooperation approach by expanding a diverse range of procurement partners and promoting deeper participation by resource countries in technology R&D and industry chain value-added, thereby avoiding the risks of dependence on a single partnership. He also noted that for the future governance of critical minerals, ESG should truly become a competitive advantage for enterprises rather than a trade barrier, with its original purpose being to optimize environmental management, improve social responsibility, and empower enterprises to enhance quality and efficiency. In the face of a new round of industrial transformation, critical minerals serve as the core raw materials for energy transition, the digital economy, and the development of high-tech industries. Based on its resource endowment, Indonesia is determined to transform from a mineral resource producer into a reliable partner in the global industry chain and a co-builder of industry rules. It invites global investors, industry chain producers, and resource-producing countries to join hands, uphold the spirit of partnership, reject unreasonable additional conditions, and jointly build a new global pattern for critical minerals that is inclusive and universally beneficial. Keynote Speech: Investing in Critical Minerals Downstreaming: Unlocking the Full Value of Indonesia's Resources Guest Speaker: Todotua Pasaribu, Vice Minister, Ministery of Investment and Downstream Industry of Indonesia Pasaribu Todotua stated that against the backdrop of climbing global demand for critical minerals and concentrated resource origins, the strategic attributes of this category continue to stand out. Indonesia, leveraging its resource endowment, vigorously promotes the downstream transformation of the entire industry chain, which is a core national policy to boost the economy and optimize supply chain structures. Under the president's policy deployment, Indonesia has designated mineral deep processing as a pillar of industrial upgrading. The authorities have delineated 28 categories of strategic minerals across eight major sectors and estimated potential investment in related tracks at approximately $618 billion, which is expected to create 3 million new jobs annually upon implementation. The country has set investment attraction targets from 2024 to 2029, accompanied by annual implementation plans. The 2026 target is clear, and investment implementation progress in the first quarter has been steady. In recent years, downstream industry investment has accounted for nearly 30% of national fixed asset investment, becoming a key driver to boost the economy and helping the country sprint toward the 8% economic growth target by 2029. He introduced that Indonesia has already established downstream layouts in multiple critical mineral tracks, including nickel, tin, aluminum, copper, PV raw materials, and semiconductor raw materials. The nickel industry has extended from stainless steel production to the entire power battery industry chain, while the tin, aluminum, and copper sectors continue to expand into deep processing, electronic materials, and other high-value-added categories, synchronously deploying supporting industry chains for PV and semiconductors. To solidify the conditions for industrial implementation, Indonesia has optimized the business environment in three aspects: accelerating approval processes, providing infrastructure support, and offering policy incentives. It has shortened project approval cycles, improved supporting facilities for hydropower, ports, and transportation, and implemented supportive measures such as tax reductions and tariff preferences, continuously attracting global capital and technological cooperation. This drives the country's transformation from a raw material exporter to a high-value-added product manufacturer, relying on multi-party collaboration to convert local mineral resources into sustainable industrial benefits. Guest Speaker: Ciyong Zou, Deputy to the Director General and Managing Director of the Directorate of Technical Cooperation and Sustainable Industrial Development, UNIDO (United Nations Industrial Development Organization) Zou Ciyong said global demand for critical minerals continues to rise along with the rapid development of clean energy and digital industries, and the role of resource countries in ensuring stable mineral supply is becoming increasingly critical. Indonesia's transformation path from raw material extraction to deep processing can provide reference for resource countries in the Global South. Currently, mining development still faces multiple challenges such as environmental protection, carbon emissions, and livelihood supporting facilities. Sustainable development has become an imperative for the industry, which needs to balance economic benefits, green development and social inclusion. Leveraging its multilateral platform advantages, UNIDO empowers its member states in multiple dimensions, including industrial policy, technology transfer, investment and financing, and capacity building, promotes the establishment of a Global Green Mining Cooperation Alliance, and has implemented a demonstration project of the Indonesia Nickel Industry Eco-Industrial Park, using the project as a model to explore a sustainable development path for global mining. He pointed out that the long-term development of the critical minerals industry cannot be separated from in-depth international cooperation, and it is necessary to establish transparent public-private partnerships, build resilient supply chains, and uniformly implement common industry standards. Indonesia intends to join forces with partners from all sectors to tap the development potential of the industry, while insisting on placing environmental protection and sustainability at the forefront of industrial development. In the future, UNIDO will continue to engage with governments, industries and capital from multiple parties, working together to achieve coordinated economic, social and environmental benefits from mineral resources. Keynote Speeches Keynote Speech: Beyond Volume: How North Maluku Can Lead Indonesia’s Next Phase of Sustainable Downstream Growth? Guest Speaker: Sherly Tjoanda, Governor of North Maluku Province Sherly Tjoanda elaborated on how North Maluku can lead Indonesia's next phase of sustainable downstream development from the perspectives of geographical location, transportation advantages, skilled talent reserves, and the fact that North Maluku's nickel ore is high-grade ore. Keynote Speech: Two Decades of Critical Minerals: 2016-2036 - How Supply Structures Shape Market Dynamics Guest Speaker: Shirley Wang, VP, Shanghai Metals Market The Rule —Why resource-rich nations must process, not just mine A 1931 Question: Mine Today, or Wait? Hotelling gave mining a theoretical anchor. It was elegant — and incomplete. A rational resource-based country should ensure the rate of price increase is exactly equal to the return on investment (Interest rate) Four Reasons the Real World Departs from the Formula Substitution, policy shifts, demand surprises, and costs — each bends the expected path The Quiet Force Behind All of This Ore grades decline everywhere. Building downstream is not ambition. It is adaptation. Shirley analyzed this by comparing ore grades for nickel, tin, copper, alumina, and others for the years 2016, 2026, and 2036. ► Strategic Insight: Why Low-Grade Ore Is Changing the Rules • Continuously declining grades are forcing industrial upgrading and iteration. Deteriorating raw ore quality is driving mines and smelters to optimize production, increasing the utilization of low-grade ore, the application of new processes, and the recycling of secondary resources. • Pricing power is gradually shifting from trading markets to resource-rich governments. As high-grade mineral deposits are depleted, the impact of short-term supply and demand on prices weakens, and the pace at which resource-rich nations release supply becomes the core variable. Industry Mainline: Commonalities in Two Decades of Development Across Five Metals Nickel: Where One Country Anchors the Market Indonesia influences marginal incremental nickel supply, and the commissioning pace of its domestic industry dominates global nickel price movements. The analysis incorporated the global distribution of nickel mine capacity. Cost Structures Are Moving Apart RKEF costs face the steepest climb. Scale mattered yesterday. Cost discipline matters tomorrow. The Ore Base Is Quietly Shifting Looking at changes in the global nickel production cost structure, the primary low-cost raw material was high-grade primary nickel ore before 2015. From 2016 to 2026, the share of low-grade ore and laterite nickel ore mining has been climbing steadily. Currently, laterite nickel ore stands as the most cost-competitive raw material. As laterite nickel ore grades decline, future nickel production based on sulphide ore may increase. Keynote Speech: Indonesia's Green Nickel: From Us To The Next Generation Guest Speaker: Joseph Hong, President Commissioner, Neo Energy Keynote Speech: AI is NOT optional! Guest Speaker: Adam Fan, Chairman of SMM Adam noted that AI has become an essential requirement for the digital upgrade of the commodity industry. Leveraging a new AI technology system, SMM integrates macro and micro data, market intelligence, and industrial information through full-process intelligent processing, and with human-machine collaboration automatically generates in-depth industry reports — surpassing traditional manual approaches comprehensively in terms of timeliness, coverage, personalization, and depth of analysis. SMM has now deployed a mature industry AI solution: leveraging SMM’s massive database and customized AI capabilities, enterprises can enable intelligent inquiries, interactive reviews, and dynamic strategy simulations, accurately serving transaction analysis, production planning, and inventory strategies for non-ferrous metals such as cobalt, nickel, and copper. SMM AI Data Services offer a three-tier progressive intelligent solution for the metals industry: Instant Inquiry → Xiao Jin (Metrix): access real-time price trends and market insights, with data sourced from a premium subscription-grade database and insights calibrated by senior analysts; In-depth Research → Deep Report: a chapter-by-chapter analysis by product and region, featuring traceable charts and citations, and continuously updated as market conditions evolve; System Integration → MCP Data Services: covering over 200,000 real-time data indicators and more than 60 products across the entire industry chain, a single integration embeds the service into the enterprise AI framework. Keynote Speech: Indonesia's Post-Election Economy: Can the Country Sustain 5–6% Growth Amid Fiscal Pressures, Weak Export Prices and Heavy Industrial Power Subsidies? Speaker: Andre Simangunsong, Head of Mandiri Institute, Office of Chief Economist, Bank Mandiri Andre Simangunsong said Indonesia’s GDP grew by 5.6% in Q1 2026, with a full-year baseline forecast of 5.2%. The strong Q1 growth was primarily driven by a low base effect from delayed fiscal spending in 2025 and the front-loading of this year’s fiscal disbursements. The full year faces uncertainties from rising crude oil prices, geopolitical fluctuations, and a widening fiscal deficit. The 2026 fiscal budget is approximately IDR 2,000 trillion, focusing on eight key areas such as education and food security; 19 major industrial projects have already commenced, with nickel smelting and industry chain parks accelerating establishment, propelling the mineral sector’s transformation from raw resource exports to high-value-added deep processing. Indonesia has revised nickel ore royalty rules, introducing progressive royalty rates, promoting the upgrade of nickel products from nickel pig iron (NPI) to MHP and nickel sulphate, and laying out hydrometallurgical processing for low-grade ores; the outlook for the tin industry is positive. The banking sector’s loan-to-deposit ratio remains stable at 85%, and Bank Mandiri is advancing digital transformation and ESG-compliant lending to empower downstream industry projects. By combining industrial, fiscal, and financial strengths, Indonesia is expected to maintain a growth range of 5%–6% in the medium and long term. CXO Panel: Senior Executives' Roadmaps to Overcome Resource, Cost, Technology & ESG Challenges Moderator: Laksmi Kusumawati, Director of Downstream Planning and International Economic Cooperation, Ministry of National Development Planning/Bappenas Panelists: Bernardus Irmanto, President Director, PT Vale Indonesia Alex Sun, Chief Sustainability Officer and Vice President, Integrated Energy Service and Carbon Management, Envision Group Marvin R. Reinhart, Portfolio Management Department Head, Indonesia Battery Corporation Ilhamsyah Mahendra, Production & Commercial Director, PT Timah Tbk Keynote Speech: Breaking the Diesel Dependency: Reliable, Affordable Energy for Island Mines Speaker: Mr. Fred Ge, C&I BESS Technical Solution Manager in Asia-Pacific, Sungrow Panel Discussion: The "Green Premium" Myth vs. Reality: Who Will Pay for Decarbonization in the Critical Minerals Supply Chain? Moderator： MARCO KAMIYA， UNIDO Representative, Regional Office in Jakarta for Indonesia, Timor Leste and the Philippines UNIDO (United Nations Industrial Development Organization) Panelists: Ary Sudijanto, Deputy for Climate Change Control and Carbon Economic Value Governance, Ministry of Environment, Government of Indonesia Antti Koulumies, CEO, Terrafame Anna Stancher, Senior Project Manager, Responsible Minerals Initiative Yumo Li, Head of ESG Office in Tsingshan Board, Tsingshan Holding Group Lihui Sun, Vice President, Chief Sustainability Officer, Huayou Cobalt Cocktail Party We extend our sincere gratitude to the global logistics leader Access World for its exclusive sponsorship of the cocktail party at this conference. Founded in 1933, Access World has grown from a family business into an international logistics organization operating in 25 countries, with a strategically located network of ports and warehousing facilities in prime locations, ensuring the efficient daily handling and flow of goods. As an end-to-end logistics service provider, Access World has long been committed to simplifying global supply chains and enhancing the efficiency of commodity circulation. It is worth noting that this marks the second consecutive year Access World has generously sponsored the cocktail dinner at the Indonesia Mining Conference & Critical Minerals Conference. For this steadfast commitment and dedication to deeply cultivating the industry and continuously empowering industry exchanges, the organizing committee and all attendees express our deep respect and gratitude. Check-in & Networking

The application for the first batch of 2026 municipal fixed-asset investment PV power generation projects from the Beijing Municipal Development and Reform Commission (NDRC) closes today (June 12). Projects that support building-integrated photovoltaics (BIPV) and those using perovskite, cadmium telluride, and other new-type cell modules will be preferred. In principle, such projects should have a construction scale of no less than 500 kW and may receive construction investment support of no more than 30%. Applying projects must commit to starting construction before the end of July 2026 and being connected to the grid by December 31, 2026.

According to overseas media reports, London-listed Pensana announced that construction of the Longonjo rare earth mine in Angola is progressing as planned, with a total investment of $250 million, targeting first commissioning and production of mixed rare earth carbonate (MREC) in 2027. The mine has a life of 20 years, with initial annual production of 20,000 mt of mixed rare earth carbonate, expanding to 40,000 mt in the fourth year. $36 million has been invested in the development of the mine and beneficiation plant, and main construction works are 22% complete. Manufacturing of long-lead equipment is progressing well, with committed procurement capital expenditure of approximately $135 million. The company is optimizing the heavy rare earth recovery circuit, targeting over 122 mt per year of dysprosium and terbium, positioning Longonjo as one of the largest heavy rare earth producers in the Western world. The modular separation facility can be expanded with mine expansion and includes a metallization circuit. Pensana has signed a non-binding memorandum of understanding with Toyota Tsusho for the offtake of up to 20,000 mt per year of mixed rare earth carbonate from Longonjo for a five-year term. The company has established a multi-partner offtake framework covering Japan's Toyota Tsusho, US-based ReElement Technologies, and US/Germany-based VAC/eVAC Magnetics. The project has received a $165 million strategic investment from Cascade Natural Resources and debt financing from ABSA, with political and commercial risk insurance provided by the US Export-Import Bank.

The British Columbia Supreme Court has ordered provincial authorities to revisit the consultation process for Seabridge Gold’s KSM project, ruling that the government failed to adequately consult the Tsetsaut Skii km Lax Ha Nation before determining the project had been substantially started. With an estimated capital cost of C$8.8 billion, KSM is one of the world’s largest undeveloped gold-copper projects and hosts approximately 7.3 billion pounds of copper reserves. The ruling could introduce additional uncertainty to the project’s permitting and development timeline, highlighting ongoing challenges related to Indigenous consultation and environmental approvals in Canada’s mining sector.

Indonesia has officially activated one of the most structurally significant commodity trade reforms in its recent history. On May 20, 2026, President Prabowo Subianto signed Government Regulation (PP) No.24/2026 on the Governance of Strategic Natural Resource Commodity Exports (State Gazette No.58, Supplementary State Gazette No.7178), which took effect on June 1, 2026 per Article 10. The regulation designates Danantara Sumberdaya Indonesia (DSI) as the mandatory sole export intermediary for all shipments of coal, palm oil, and ferro alloys. No Indonesian producer in these categories can sell directly to a foreign buyer anymore. Every transaction must legally pass through DSI first. The constitutional grounding is explicit. The preamble invokes Article 33 of the 1945 Constitution, which establishes that natural resources are controlled by the state and must be used for the greatest possible benefit of the Indonesian people ( sebesar-besar kemakmuran rakyat ). The regulation's explanatory notes go further, stating that "so long as the state possesses the capital, technology, and management capability to manage Strategic SDA Commodities, the state should undertake direct management," and that doing so ensures "all results and profits will become state revenue bringing more optimal benefits for the welfare and prosperity of the people." This is framed not as a technical trade regulation but as a matter of constitutional duty. The explanatory notes to Article 7 explicitly name the five digital systems through which DSI will exercise oversight: CEISA (Customs Excise Information System and Automation), SINSW (Indonesia National Single Window), INATRADE (Trade Information System), SiMoDIS (Integrated Foreign Exchange Monitoring System), and MOMS (Minerba Online Monitoring System). Real-time visibility across all five platforms forms the enforcement backbone of the entire reform. On June 9, Minister of Energy and Mineral Resources Bahlil Lahadalia and DSI COO Dony Oskaria offered three key reassurances at a press conference to calm investor sentiment. Oskaria confirmed that existing B2B contracts and Letters of Credit will continue to be honored during the transition period, provided DSI's monitoring system confirms that pricing is fair and transparent. Bahlil categorically denied market rumors of a "profit-sharing" mechanism in the minerals sector, stating that this concept applies only to oil and gas and that Minerba rules remain unchanged. He also committed to aligning RKAB mining quotas with smelting capacity and promised quota relaxations during periods of highly favorable global prices. June 8th DPR RI Coordination Hearing: What Bahlil and Dony Oskaria Actually Said The Indonesian House of Representatives (Dewan Perwakilan Rakyat Republik Indonesia / DPR RI) convened a coordination hearing to align the new natural resource export governance policy between Danantara's Investment Management Agency (BPI Danantara) and the Ministry of Energy and Mineral Resources (Kementerian ESDM). The session featured Minister Bahlil Lahadalia representing ESDM and DSI COO Dony Oskaria representing BPI Danantara. Oskaria opened by clarifying the precise scope of DSI's mandate in its initial phase. He confirmed that DSI's primary and immediate purpose is to halt under-invoicing and transfer pricing — not to disrupt physical commodity flows. He gave explicit assurance that existing B2B sales contracts and Letters of Credit will continue to be honored and executed normally during the transition period, with one condition: DSI's digital monitoring system must determine that the declared pricing is fair and reflects genuine market values. Any contract where declared prices are flagged as suspiciously below market will be subject to DSI scrutiny, but standard commercially negotiated contracts should proceed without interruption. Bahlil addressed three distinct concerns that had been circulating in the market. First and most urgently, he categorically denied rumors of a "gross split" profit-sharing mechanism being introduced into the minerals sector. He stated directly that gross split calculations exist only in the oil and gas sector and that there are "absolutely no changes" to the existing rules governing the minerals and coal (Minerba) space. This denial was significant because the rumor alone had been enough to cause investors to reconsider capital commitments to Indonesian smelting projects. Second, Bahlil acknowledged the domestic ore supply squeeze that has been tightening around Indonesian smelters, and committed to aligning RKAB mining quotas with downstream smelter capacity. He promised "measured relaxations" of production limits during periods when global commodity prices are highly favorable, signaling that the government has no interest in strangling the smelting industry it has spent years building. Third, on the broader question of investment security, Bahlil framed DSI as a value-capture mechanism rather than a market interference tool — the government wants more of the revenue that Indonesian commodities generate to stay in Indonesia, not to reduce the volume of those commodities being exported. What the Regulation Actually Says: Key Articles Reading PP No.24/2026 directly, several provisions carry commercial implications beyond what the market has fully absorbed. Article 3(1) establishes the core mandate: strategic commodities may only be exported by the BUMN Ekspor, acting either as owner or as sole intermediary. The word hanya ("only") in the Indonesian text is unconditional. Article 3(2) goes further: the selling price of Strategic SDA Commodities is determined by the BUMN Ekspor. This is not a transparency or monitoring function — DSI holds formal pricing authority over every export transaction. Article 3(4) confirms that DSI may charge a margin at a reasonable level in accordance with prevailing regulations, meaning DSI is legally entitled to a fee for its intermediary role. The combination of state-determined selling price and a state-imposed margin on every nickel and ferro alloy export has not yet been fully digested by the market. Article 4(2) contains the most important exemption in the regulation. DSI's mandatory intermediary role can be waived for business operators who hold contracts or agreements with the government that include provisions on at minimum: investment, divestment, and domestic processing and/or refining. Exemptions are decided in a coordination meeting chaired by the Coordinating Minister for Economic Affairs. For the nickel sector, this is a critical provision, any smelter with an existing government contract containing these three elements has a legal pathway to apply for exemption from DSI routing entirely. Article 7 governs the full transition timeline. It states that from June 1 through no later than December 31, 2026, exports must go through BUMN Ekspor. Within three months of the effective date — meaning by approximately September 1, 2026 — a formal inter-ministerial evaluation must take place. Based on that evaluation, the Coordinating Minister has the authority to set a new deadline that is either earlier or later than originally planned, provided it remains before December 31. This is a genuine two-way valve: if the transition is going well, implementation can be accelerated; if problems emerge, the government can extend the timeline. Article 7(e) further provides that if the transition completes ahead of any applicable deadline, the full DSI-only rules apply from that earlier date immediately. Article 8 addresses existing contracts: all sales contracts signed before June 1, 2026 that remain valid are subject to evaluation by the BUMN Ekspor. DSI holds formal authority to assess every pre-existing long-term purchase agreement, including those between Indonesian smelters and their Chinese offtake partners. Critical Dates and Deadlines: The Full Regulatory Calendar May 20, 2026 — PP No.24/2026 signed by President Prabowo Subianto. June 1, 2026 — Regulation takes effect. Phase 1 begins. CEISA 4.0 mandatory DSI reporting pop-up activated. Pre-June 1 sales contracts enter DSI evaluation period under Article 8. By ~September 1, 2026 — Mandatory inter-ministerial evaluation of the transition (Article 7b). This review is a legal obligation, not optional. Its outcome determines the pace of everything that follows: the Coordinating Minister may accelerate, maintain, or extend the timeline to any date before December 31. September 1, 2026 — Phase 1.5 begins (unless the evaluation resets the timeline). PEB Box 6 changes to BUMN Ekspor (DSI). QQ document format begins. Companies act as DSI's legal agents. December 31, 2026 — The hard outer ceiling (Article 7a). After this date, no transitional exceptions remain. Only DSI may export, unconditionally. The Coordinating Minister cannot extend beyond this date. January 1, 2027 (or earlier if accelerated) — Phase 2 full implementation. DSI is the sole legal exporter. DSI drafts all contracts and L/Cs, handles all customs clearance, and reports DHE directly to Bank Indonesia via SiMoDIS. The NPI Classification Crisis The inclusion of ferro alloys has created the most significant market confusion, centered on a single unresolved technical problem: where Nickel Pig Iron sits relative to the regulated ferro-nickel HS code. Ferronickel (FeNi) is a mature, refined iron-nickel alloy produced through capital-intensive smelting, typically containing 20–40% nickel . It is a direct feedstock for stainless steel production and commands a meaningful price premium. Nickel Pig Iron (NPI) was developed in China in the mid-2000s as a low-cost alternative, produced via the simpler Rotary Kiln-Electric Furnace (RKEF) process using laterite ore. Indonesian RKEF-line NPI consistently produces at 10–14% Ni — a structural result of the process and the ore body, not a product specification smelters can adjust. NPI trades at a significant discount to FeNi, and any trader or stainless steel mill can distinguish the two products immediately. The problem is that Indonesia's customs classification framework cannot reliably tell them apart. Both products can fall under HS 7202.60 (ferro-nickel), and Indonesian NPI smelters have historically declared under that code without issue. Under Permendag No.12/2026, HS 7202.60.00 is now DIATUR (Regulated) — triggered when Ni content reaches ≥ 8% . The Ministry of Trade chose this as the demarcation: refined FeNi at 20–40% Ni would clearly exceed it, while NPI was assumed to fall below it and escape the regulation. That assumption fails entirely. Standard Indonesian RKEF output runs 10–12% Ni; higher-grade lines reach 12–14% Ni. There is no commercially significant NPI stream below 8% Ni under normal operating conditions. The threshold sits below average grade Indonesia actually produces, meaning every Indonesian NPI shipment technically triggers under the regulated classification, capturing precisely the product the government intended to exempt. Internal Rakortek documents confirm the Coordinating Minister directed that NPI should not be captured. The discussion slides acknowledge the collision and propose corrective steps: set a threshold above actual RKEF NPI norms, issue binding technical definitions for NPI, and align classification consistently across HS 7201 (pig iron), 7202.60 (ferro-nickel), and 7502.20 (nickel alloys). None of that supplemental guidance has been published yet. Strategic Outlook: The September Evaluation Is the Pivot Point The most important thing to understand about PP No.24/2026's near-term trajectory is that the regulation has deliberately built in a recalibration mechanism — and that mechanism has not been priced into most market participants' planning. Article 7(b) and 7(c) together create a genuine two-way valve. The September evaluation is a legally mandated inter-ministerial review that gives the Coordinating Minister real authority to reset the timeline in either direction. If the first three months reveal that DSI is not operationally ready, and the Rakortek checklists, which showed nearly every DSI readiness item as incomplete as of May 25, suggest that risk is real — the Coordinating Minister can formally extend the transition and push the QQ phase and beyond to a later date before December 31. Equally, if the reporting data flowing through CEISA, SiMoDIS, and MOMS shows that compliance is working smoothly and DSI is ready, the same evaluation could authorize an accelerated Phase 2 arrival, potentially as early as October or November 2026. What is not negotiable is the December 31, 2026 ceiling. Articles 7(a) and 7(d) together make clear that this is the absolute outer boundary of the Coordinating Minister's authority. Regardless of what the evaluation finds, the transition cannot be extended beyond December 31. After that date, except for legally approved exemptions, DSI is the sole legal exporter and no amount of industry pressure or operational unreadiness changes that. The Article 4(2) exemption pathway remains the most immediately actionable provision for smelters with qualifying government contracts. Any agreement containing investment, divestment, and domestic processing provisions should be reviewed against that exemption criteria now. Engaging the Coordinating Minister's coordination meeting process before the September evaluation is concluded is far preferable to doing so afterward. On NPI, the plain text of Permendag No.12/2026 as it stands today classifies Indonesian NPI as regulated. Smelters should not wait for the Ministry of Trade's supplemental guidance before beginning compliance preparation. Seeking an advance product classification ruling, exploring the Article 4(2) exemption if applicable, and building DSI integration workflows in parallel remains the most prudent path. The December 31 deadline, or whatever earlier date the post-evaluation acceleration may set, is not the end of the story. It is the point at which the entire B2B architecture of Indonesian strategic commodity exports permanently and irreversibly changes. SMM Analysis makes no representations as to the official legal interpretation of any regulation cited. Stakeholders should seek formal legal counsel for all compliance decisions.